ML20003G612
| ML20003G612 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/23/1981 |
| From: | Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | CITIZENS FOR FAIR UTILITY REGULATION |
| References | |
| NUDOCS 8104300258 | |
| Download: ML20003G612 (19) | |
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April 23, 1981 d .y 6 0 IS81 h . UNITED STATES OF AMERICA .
D g ros, NUCLEAR REGULATORY COMMISSION Sg
\ EFORE THE ATOMIC SAFETY AND LICENSING BOARD C D ,7,, f 4,
% 04 bch In the Matter of ) (fIgg\
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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, - _al.
et ) 50-446 (Comanche Peak Steam Electric ) (Application for-Station, Units 1 and 2) ) Operating License)
APPLICANTS' THIRD SET OF INTERROGATORIES TO CFUR AND REQUESTS TO PRODUCE Pursuant to 10 C.F.R. $$2.740b and 2.741, Texas Utilities Generating Company, et al. (" Applicants") hereby serve Applicants' Third Set of Interrogatories and Requests to Produce upon Citizens for Fair Utility Regulation ("CFUR").
Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all pertinent information l
l known to CFUR, its officers, directors or members as well as any pertinent information known to its employees, advisors or counsel. Each request to produce applies to pertinent documents which are in the possession, custody or control of CFUR, it.s officers, directors or members as well as its employees, advisors or counsel. In answering each interrog-atory and in responding to each request, please recite the interrogatory or request preceding each answer or response.
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0 Also, please identify the person providing each answer or response. 1/
These interrogatories and requests shall be continuing in nature. Thus, any time CFUR obtains information whiah renders any previous response incorrect or indicates that a -
response was incorrect when made, CFUR should supplement its previous response to the r.npropriate interrogatory or re-quest to produce. CFUR should also supplement its responses as necesaary with respect to identification of each perso'n expecte,d to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony. The term " documents" shall include any writings, drawings, graphs, charts, photographs, and other data compilations from which information can be obtained.
We request that at a date or dates to be agreed upon, CFUR make available for inspection and copying, all documents subject to the requests set forth below.
APPLICANTS' INTERROGATORIES AND REQUESTS TO PRODUCE Contention 3: The computer codes used in CPSES/FSAR must be tested and, if necessary, modified to accept the parameters reflecting the sequence of events at Three Mile Island and then to realistically predict plant behavior.
1,/ The instant discovery requests directed to CFUR concern Contentions 3, 4 and 9. The Board designated CFUR lead party-intervenor for consolidated Contention 4 for all purposes in this proceeding, which includes discovery.
CFUR is the sole sponsor of Contentions 3 and 9. Memo-randum and Order, December 31, 1980. If, however, any other Intervenor possesses information or documents re-quested herein with respect to these contentions which CFUR intends to use in support of its position, such information or documents should be provided in response to these interrogatories and requests to produce. ,
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i 1-3. 2/
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What is your basis for contention 37 Please list all documents not elsewhere identified in your
. responses to these interrogatories on which you rely with respect to Contention 3. Please provide copies of all such documents for inspection and copying.
2-3. Have you prepared any report, study or analysis with respect to Contention 37 If so, please identify each such report, study or analysis by subject and author, including the author's professional and educational background. Please provide each sucit report, study or analysis for inspection and copying.
3-3. Have you caused others to prepare any report, l study or analysis with respect to Contention 37 t
If so, please identify each such report, study or analysis by subject and author, including i the professional and educational background of the author. PleaJe provide for inspection and copying each auch report, study or analysis on which you intend to reply.
t i 4-3. Have you had any meetings or contacts with the
( other intervening parties with respect to I Contention 37 If so, please specify the purpose of such meetings or contacts and the results of such meetings or contacts.
5-3. What are the dates of the meetings or contacts you have had with persons other than the inter-l vening parties with respect to Contention 37 I Please identify the purpose of those meetings or contacts, the other persons involved, and the results of such meetings or contacts.
6-3. Do you plan to participate in the upcoming hear-ing with respect to Contention 37 If so, what will be the extent of your participation?
7-3. Do you plan to file testimony in the upcoming hear-ing with respect to Contention 3? If so, who will be the sponsor (i.e. , witness) of that testimony?
_ Please set forth the nature of such testimony and the professional and educational background of the 2/ Applicants have identified these interrogatories as the third set to CFUR by the hyphen 3 following each number.
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witness. Please provide copier of the testimony. ,
Also, please identify by title, subject matter and
. author, and provide for inspection and copying, any documents which any such testimony will rely upon.
8-3. Do you plan to call any witness in the upcoming i hearing with respect to contention 37 If so, please provide a summary of his or her professional and educational background. Also, set forth any informa-tion which has a bearing on his or her qualifications to testify in this proceeding on contention 3.
l 9-3. If you plan to call any witness in the upcoming hearing with respect to Contention 3, please specify the nature and scope of that person's testimony.
Please provide copies of such testimony. Please state whether that witness has conducted any research or made any studies on which the witness intends to rely. Also, identify by title subject matter, and ,
author, and provide for inspection and copying, any document on which such witness will rely in their
- testimony with regard to Contention 3.
10-3. Have you reviewed the Applicants' Final Safety
-Analysis Report ("FSAR")? If not, please explain.
If so, please answer the following:
- a. Do you object to any of the information, data or analyses contained or referenced therein with respect to computer codes?
- b. If your answer to a. is in the affirmative, please identify those objections by the section of the FSAR to which you object and the substance of your objection.
- c. If your answer to a. is in the affirmative, 1
please specify in what way the information, data or analyses concerning computer codes does not satisfy the concerns raised in Contention 3.
- d. What are your bases (legal and/or other) for
- your responses to a. through c.?
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11-3. Please identify all " computer codes" with which you are concerned in contention 3. Identify those codes by providing a reference to that code (identify the document and page number), the purpose of the code, and any name or designation applied to the particular code.
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12-3. For each of the " computer codes" identified in your response to Interrogatory 11-3, specify the manner in which those codes are "used in" the Comanche Peak FSAR.
13-3. Describe in detail the tests which you contend must be performed on Ehe computer codes identified in your response to Interrogatory 11-3. Specify 3
who you believe should conduct those tests and what the tests should be designed to discover.
14-3. What are the specific criteria by which you contend the computer codes which are the subject of Contention 3 should be judged to determine if it.
"necessary" to mc_ify those codes? List every factor which you believe should be included in those criteria and specify which factors or combinations of factors must be met in order for the computer codes to be considered adequate and not required to be modified. .
15-3. Describe in detail the manner in which you contend l
each of the computer codes identified in your l response to Interrogatory 11-3 should be " modified".
10-3. Who do you contend should perform the modification of Ehe computer codes described in your response l to Interrogatory 15-37 i
17-3. What are your bases (legal and/or other) for your responses to Interrogatories 11-3 through 16-37 18-3. Describe what you contend must be done to the computer codes identified in your response to Interrogatory 11-3 so that those computer codes can " recept the parameters" which you contend in Contention 3 should be accepted?
19-3. Specify the particular capabilities which you contend the computer codes which are the subject of Contention 3 will have if they are modified in the manner described in your response to Interro-gatory 15-3 which capabiltiles these computer ccdes do not now have.
20-3. Specify each " parameter" which you conten'd'must be reflected in the computer codes which are _
the subject of Contention 3.
21-3. For each "paramenter" you list in your response to Interrogatory 20-3, specify the manner in which you contend that parameter would affect the com-puter codes which are the subject of Contention 3.
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22-3. For each parameter identified in your response to Interrog tory 20-3, please specify the differ-ences between the way you contend those paramet-ers would affect the Comanche Peak facility and the way in which those parameters affected the Three Mile Island Unit 2 facility.
23-3. Identify precisely the " sequence of events at Three Mile Island" which you contend must be reflected in the computer codes which are tha subject of Contention 3. In describing this sequence of events, please set forth in detail the initiating events, the reaction of each component to that initiating event and the consequences of those reactions. .
24-3. Do you contend that the computer codes which are.
the subject of Contention 3 do not reflect the sequence of events identified in your response to Interrogatory 23-37 25-3. What are your bases (legal and/or other) for your responses to Interrogatories 18-3 through 24-37 26-3. In your previous pleadir.gs you have identified
" operator error" as a parameter which must be incorporated into the computer codes which are the subject of Contention 3. Please set forth a description of each such " operator error" and the consequences which you contend flow from that error.
27-3. For each " operator error" identified in your i response to Interrogatory 26-3, describe the t error in a manner which would permit inclusion of such a factor in the computer codes which are the subject of contention 3, i.e., in mathematical i terms.
28-3. In your previous pleadings you have identified
" maintenance error" as a parameter which you contend should be included in the computer l codes for Comanche Peak. Describe each such
" maintenance error" which you contend should be considered, and set forth the consequences of each of those errors.
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29-3. Describe the " maintenance errors" identified in your response to Interrogatory 28-3 in a manner that would permit inclusion of that factor in the computer codes which are the subject of Conten-tion 3, i.e., in mathematical terms.
30-3. In your previous pleadings you have identified
" hydrogen formation" as a parameter which you contend should be included in the computer codes which are the subject of; Contention 3. Describe the specific details of such " hydrogen formation" and the consequences which you contend flow from such " hydrogen formation!."
l-31-3. Describe the " hydrogen formation" identified in your response to Interrogatory 30,-3 in terms which permit the inclusion'of that factor in* the computer codes which are the subject of Conten-tion 3, i.e., in mathematical terms.
I 32-3. In your previous pleadin's g you have identified
" single failure criterion interpretation" as a parameter which must be incorporated into the computer codes which: are the subject of Contention 3. Please set forth a description of each such " single failure criterion interpre-tation" and the consequences which you contend flow from that interpretation.
33-3. For each " single failure criterion interpretation" identified in your response to Interrogatory 32-3, describe the error in a manner which would permit inclusion of such a factor in the computer codes which are the subject of Contention 3, i.e., in mathematical terms.
34-3. In your previous pleadings you have identified "PORV problems" as a parameter which must be incorporated into the computer codes which are the subject of Contention 3. Describe each such "PORV problem" and the consequences which you contend flow from each such problem.
35-3. For each "PORV problem" identified in your response to Interrogatory 34-3, describe the problem in a manner which would permit inclusion of such a factor in the computer codes which are the subject of Contention 3, i.e. in mathematical terms.
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.i 36-3. In your previous pleadings you have identified
" misleading indications" as a parameter which must be incorporated into the computer codes which are the subject of Contention 3. Please set forth a description of each such " misleading indication" and the consequences which you contend flow from the indication.
37-3. For each " misleading indication" identified in your response to Interrogatory 36-3, describe the
- indication in a manner which would permit inclusion .
. of such a factor in the computer codes which are the subject of Contention 3, i . e., in mathematical terms.
38-3. In your previous pleadings you have identified "non-condenseable gases" as a parameter which must be somehow incorporated into the computer codes which are the subject of Contention 3. Please set forth a description of such "non-condenseable
- gases" and the consequences which you contend flow from those gases.
39-3. For each "non-condenseable gas" identified in your response to Interrogatory 38-3, describe the gas in a manner which would permit inclusion of such a factor in the computer codes which are the subject of Contention 3, i e., in mathematical terms 40-3. Set forth the specific NRC requirements which you contend require the Applicants to take the measures which you have identified in your respon-ses to each of the above interrogatories.
41-3. What do you contend the Applicants must do to demonstrate that the concerns which are the subject of Contention 3 have been adequately dealt with?
42-3. What do you contend the NRC Staff must do to demonstrate that the concerns which are the sub-ject of Contention 3 have been adequately dealt with?
43-3. What do you contend the computer codes which are the subject of contention 3 must do to " realistically predict plant behavior"7 44-3. What,are your bases (legal and/or other) for your responses to Interrogatories 26-3 through 42-37
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Contention 4: Some accident sequences heretofore con-ridered to have probabilities so low as to be considered incredible, based, in part, upon the findings of WASH-1400, are in fact more probable in light of additional findings, such as those of the Lewis Committee and should be evaluated as credible accidents for CPSES. This evaluation should in-clude a hydrogen explosion accident. In order to insure conservatism, the probabilities associated with such accident sequences should be the highest probabilities within the specified confidence band.
45-3. What is your basis for Contention 47 Please list all documents not elsewhere identified in your responses to these interrogatories on which you rely with res-pect to Contention 4. Please provide copies of all such docum9nts for inspection and copying.
46-3. Have you prepared any report, study or analysis with respect to Contention 47 If so, plesse identify each such report, study or analysis by subject and author, including the author's professional and educational background. Please provide each such report, study or analysis for inspection and copying.
47-3. Have you caused others to prepare any report, study or analysis with respect to Contention 47 If so, please identify each such report, study or analysis by subject and author, including the professional and educational background of the author. Please provide for inspection and copying each such report, study or analysis on which you intend to rely.
48-3. Have you had any meetings or contacts with the other intervening parties with respect to Contention 4? If so, please specify the purpose of such meetings or contacts and the results of such meetings or contacts.
49-3. What are the dates of the meetings or contacts you have he.d with persons other than the intervening parties with respect to Contention 47 Please identify the l
purpose of those meetings or contacts, the other per-sons involved, and the results of such meetings or contacts.
50-3. Do you plan to participate in the upcoming hearing with respect to Contention 4? If so, what will be the extent of your participation?
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51-3. Do you plan to file testimony in the upcoming hear-i ing with respect to contention 47 If so, who will be the sponsor (i.e. , witness) of that testimony? Please set forth the nature of such testimony and the profes-sional and educational background of the witness.
Please provide copies of that testimony. Also, please identify by title, subject matter and author, and pro-vide for inspection and copying, any documents which
, any such testimony will rely upon.
t 52-3. Do you plan to call any witness in the upcoming hear-ing with respect to Contention 47 If so, please ,
. provide a summary of his or her professional and educational background. Also, set forth any informa-tion which has a bearing on his or her qualificationa to testify in this proceeding on Contention 4.
! 53-3. If you plan to call any witness in the upcoming i
hearing with respect to contention 4, please specify the nature and scope of that person's testimony.
! Please provide copies of such testimony. Please
! state whether that witness has conducted any research j or made any studies on which the witness intends to ,
l rely. Also, identify by title subject matter, and ,
, author, and provide for inspection and copying, any l document on which such witness will rely in their testimony with regard to Contention 47
- 54-3. Have you reviewed the Applicants' Final Safety Analysis Report ("FSAR")7 If not, please explain. If so,
, please answer the following.
i a. Do you object to any of the information, data or analyses contained or referenced therein with respect to the evaluation of accident sequences?
l b. If your answer to a. is in the affirmative, please
- identify those objections by the section of the FSAR to which you object and the substance of your objection.
- c. If your answer to a. is in the affirmative, please specify in what way the information, data or analyses concerning the evaluation of accident sequences does not satisfy the concerns raised in Contention 4.
- d. What are your bases (legal and/of other) for your responses to a. through c.?
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55-3. Describe in detail the " accident sequences" which you contend in Contention 4 should be considered
" credible accidents" for Comanche Peak. For each such " accident sequence," specify the initiating event, the series of events which follow and the consequences of each accident sequence.
- 56-3 Please describe in detail the type of accident which you contend is a " credible accident" for Comanche
- Peak.
57-3. Identify the specific " findings of WASH-1400" with which Contention 4 is concerned. Identify these particular findings by a brief description and a
- reference to the page number of WASH-1400 where each is found.
58-3. Identify and describe in detail the " additional findings".which render the accident sequences evaluated in WASH-1400 more probable.
59-3. Identify the findings of the Lewis Committee
- which have made the accident sequences which are the subject of Contention 4 "more probable."
60-3. Specify the change in " probabilities" which has occurred as a result of these " additional findings."
61-3. Precisely what factors do you contend should be considered in determining whether an accident is
" credible"?
62-3. What is the lowest probability for an accident, I i.e., least likely to occur, which should be i
considered as a " credible" accident at a nuclear power reactor?
63-3. What is the lowest probability accident which you contend should be considered as a " credible" accident for Comanche Peak's If your answer to this interrogatory is different from your answer to Interrogatory 62-3, please explain the reason for that difference.
64-3. What are your bases (legal and/or other) for your responses to Interrogatories 55-3 through 63-3?
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65-3. Describe in detail the " hydrogen explosion accident" which you contend should ba evaluated?
66-3. What are the initiating events which you contend are part of the " hydrogen explosion accident" which must be evaluated?
67-3. What amount of hydrogen do you contend would be generated in the " hydrogen explosion accident"?
68-3. What is the maximum pressure within the contain-ment which you contend the " *hydrogen explosion accident" would generate?
69-3. Describe precisely the way in which you contend the hydrogen would burn in the " hydrogen explosion accident."
70-3. What are your bases (legal and/or other) for your responses to Interrogatories 65-3 through 69-37 71-3. What is the " conservatism" which you contend must be " insured"?
72-3. What do you contend are the probabilities of each of the " accident sequences" which are the subject of Contention 47 i 73-3. Describe in detail how you calculated the probabi-
! lities identified in your response to Interroga-tory 72-3.
74-3. Describe how you contend the highest probabilities within the specified confidence band" should be calculated for the accident sequences which are the subject of Contention 4.
75-3 Precisely how do you contend the evaluations of the accident sequences which are the subject of Contention 4 should be addressed in the licensing review process for Comanche Peak?
76-3. What role do you contend the Applicants should have in performing the evaluation of the accident sequences which are the subject of Contention 47 l
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77-3. What role do you contend the NRC Staff should have in the evaluation of the accident sequences which are the subject of Contention 47 78-3. What role do you contend the Licensing Board should have in the evaluation of the accident cequences which are the subject of Contention 4?
79-3. What do you contend the Applicants must do to demon-strate that the evaluations which you contend must be performed have been. satisfactorily. completed?
80-3. What do you contend the NRC Staff must do to demonstrate that the evaluations which you contend should be performed have been satisfactorily completed?
81-3. What role do you contend the Licensing Board should do to determine that the accident sequences which are the subject of Contention 4 have been adequately evaluatod?
82-3. Identify all NRC licensinh requirements which you contend are not satisfied by the Applicants in their evaluations of accident sequences.
83-3. What are your bases (legal and/or other) for your responses to Interrogatories 71-3 through 82-37 Contention 9: Applicants have failed to make any effort to determine the effect of radioactive releases on the general public other than at the exclusion boundary.
Various transport mechanisms may cause, in certain cases, the bulk of the health effects to occur some distance from l
the exclusion boundary.
i 84-3 What is your basis for contention 97 Please list all documents not elsewhere identified in your responses to these interrogatories on which you rely with respect to Contention 9. Please provide copies of all such documents for inspection and copying.
! 85-3. Have you prepared any report, study or analysis with respect to Contention 97 If so, please identify each such report, study or analysis by j subject and author, including the author's professional and educational background. Please provide each such report, study or analysis for inspection and copying.
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1 86-3. Have you caused others to prepare any report, study or anlaysis with respect to Contention 97 If so, please identify each such report, study or analysis by subject and author, including the professional and educational background of the author. Please provide for inspection and copying each such report, study or analysis on which you intend to rely.
, 87-3. Have you had any meetings or contacts with the other intervening parties with respect to contention 97 If so, please specify the purpose of such meetings or contacts and the results of such meetings or contacts.
88-3. What are the dates of the meetings or contacts you have had with persons other than the inter-vening parties with respect to Contention 97 Please identify the purpose of those meetings or contacts, the other persons involved, and the results of such meetings or contacts.
89-3. Do you plan to participate in the upcoming hearing with respect to Contention 97 If so, what will be the extent of your participation?
90-3. Do you plan to file testimony in the upcoming hearing with respect to Contention 97 If so, who will be the sponsor (i.e. , witness) of that testimony? Please set forth the nature of such l
testimony and the professional and educational l background of the witness. Please provide j copies of that testimony. Also, please identify t by title, subject matter and author, and provide for inspection and copying, any documents which any such testimony will rely upon.
91-3. Do you plan to call any witness in the upcoming hearing with respect to Contention 97 If so, l
i please provide a summary of his or her profes-j sional and educational background. Also, set l
forth any information which has a bearing on his l or her qualifications to testify in this proceeding on Contention 9.
92-3. If you plan to call any witness in the upcoming hesring with respect to Contention 9, please specify the nature and scope of that person's testimony. Please state whether that witness
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has conducted any research or made any studies on which the witness intends to rely. Also, identify by title, subject matter, and author, end provide for inspection and copying, any document on which such witness will rely in their testimony with regard to Contention 97 93-3. Have you reviewed the Applicants' Final Safety Analysis Report ( " FSAR"-) ? If not, please explain.
If so, please answer the following:
- a. Do you object to any of the information,
- data or analyses contained or referenced therein with respect to the effect of
, radioactive releases on the general public?
- b. If your answer to a. is in the affirmative, please identify those objections by the section of the FSAR to which you object and the substance of your objection.
- c. If your answer to a. is in the affirmative, please specify in what way the information, data or analyse 9 regarding the effect of radioactive releases on the general public does not satisfy the concerns raised in Contention 9.
- d. What are your bases (legal and/or other) for your responses to a. through c.?
94-3. Describe each "effect of radioactive releases" which you contend must be considered in Contention 9.
95-3. In your description of each "effect of radio-active releases" identify the radioactive isotopes which you contend are involved in the releases.
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! 96-3. Identify the maximum dose which you contend would occur from the radioactive releases which are the subject of Contention 9.
! 97-3. What are the exposure pathways which lead to the effects which are the subject of Contention 9, e.g.,
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! ingestion, inhalation or exposure to skin? -
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98-3. Do you contend that the " effects" which are the subject of Contention 9 would be greater than those that would occur at the exclusion boundary?
99-3. What do you contend the Applicants must do to
" determine" the effects of the radioactive releases which are the subject of Contention 97 100-3. What do you contend the NRC Staff must do to
" determine" the effects of radioactive releases which are the subject of Contention 9?
101-3. Do you contend that the radioactive releases with which you are concerned in Contention 9 would occur during normal operation of the Comanche Peak facility?
102-3. Do you contend that the radioactive releases with which you are concerned in Contention 9
- would be the result of an accident at the Com-anche Peak facility?
103-3 If your answer to Interrogatory 101-3 Js in tne affirmative, please describe the specific sources of the radioactive releases during normal operation of the Comanche Peak facility with which you are concerned.
104-3. If your answer to Interrogatory 102-3 is in the affirmative, describe in detail the type of accident with which you are concerned and the l
source of the radioactive releases for each l of the accidents with which you are concerned.
105-3. If your responses to Interrogatories 101-3 and 102-3 are in the negative, please specify the source of the radioactive releases with which you are concerned in Contention 9.
106-3. Describe in detail the "various transport mechan-l isms" with which you are concerned in Contention 9.
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107-3. Describe in detail the dispersion characteristics of each " transport mechanism" which you described in your response to Interrogatory 106-3. Describe any mathematical models upon which you intend to rely to describe the transport mechanisms.
108-3. What do you mean by "certain cases"?
l 109-3. Describe eacP of the "certain cases" with which l you are concerned in Contention 9. ,
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110-3. What are the " health effects" with which you are concerned in Contention 9?
111-3. Explain what you mean by "the bulk of the health effects."
112-3. What is the maximum " distance" from the Comanche Peak facility at which you contend the " health effects" with which you are concerned in Conten-tion 9 should be evaluated?
113-3. How did you arrive at the figure which you contend is the maximum " distance" for which " health effects" should be determined? -
114-3. Describe in detail the scenario which you contend should be addressed which the Applicants have not addressed and which sets forth the mechanisms for release, dispersion and exposure of persons in the manner with which you are concerned in Conten-tion 9.
115-3. Do you contend that any of the exposures with which you are concerned in Contention 9 exceed any exposure limits with which the Applicants are required to comply? If so, please identify those exposure limits and describe the extent with which you contend those limits are exceeded.
116-3. Please set forth the NRC's licensing requirements which you contend require the Applicants to determine the 'i affect of radioactive releases" in the manner with which you are concerned in l Contention 9.
l l 117-3. What are your bases (legal an ,or other) for your responses to Interrogatori -4 through 116-37 Res t 11 submitted, I r Nichy s5 . Re nolds Y ,
William %d Horin DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.
Washington, D.C. 20036 (202) 857-9817 Counsel for Applicants Date: April 23, 1981 t
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v UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I
In the Matter of )
)
TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY, -et al. ) 50-446
)
(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License)
CERTIFICATE OF SERVICE !
I I hereby cer.tify that copies of the foregoing ' Applicant!s' Third Set of Interrogatories to CFUR and Requests to Produce"
- in the above captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 23rd day of April, 1981
- ,
i Valentine B. Deale, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal-Panel l
Licensing Board U.S. Nuclear Regulatory
(
1001 Connecticut Avenue, N.W. Commission Washington, D.C. 20036 Washington, D.C. 20555 Dr. Forrest J. Remick, Member Marjorie Ulman Rothschild, Esq.
Atomic Safety and Licensing Office of the Executive Board Legal Director 7 305 E. Hamilton Avenue U.S. Nuclear Regulatory State College, Pennsylvania 16801 Commission Washington, D.C. 20555 Dr. Richard Cole, Member l
! Atomic Safety and Licensing David J Preister, Esq.
Board Assistant Attorney General U.S. Nuclear Regulatory Environmental Protection Commission Division Washington, D.C. 20555 P.O. Box 12548 Capitol Station Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel U.S. Nuclear Regulatory Mr. Richard L. Fouke Commission CFUR Washington, D.C. 20555 1668B Carter Drive Arlington, Texas 76010 i
~
Arch C. McColl, III, Esq. Mr. Geoffrey M. Gay 701 Commerce Street West Texas Legal Services suite 302 100 Main Street (Lawyers Bldg.)
Dallas, Texas 75202 Fort Worth, Texas 76102 Jeffery L. Hart, Esq. Mr. Chase R. Stephens 4021 Prescott Avenue Docketing & Service Branch Dallas, Texas 75219 U.S. Nuclear Regulatory Commission Mrs. Juanita Ellis Washington, D.C. 20555 President, CASE 1426 South Polk Street.
Dallas, Texas 75224 1
GL a#.~
William A. Ho'r in 1
1 I
cc: Homer C. Schmidt Spencer C. Relyea, Esq.
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